DATA PROTECTION POLICY
In compliance with the General Data Protection Regulation (GDPR EU 2016/679) and the Organic Law on Personal Data Protection and Guarantee of Digital Rights (LO 3/2018), HOMMYHOME has established the following policy governing the various data processing activities conducted by this entity:
HOMMYHOME informs that personal data collected through its website (www.hommyhome.com) are included in automated files owned by this entity, which have implemented appropriate security measures to ensure the accessibility, integrity, and availability of the data stored therein.
Who processes your data?
| DATA CONTROLLER DETAILS |
| Company Name: | APARTMENTS AND VILLAS MANAGEMENT S.L. (HommyHome). |
| N.I.F.: | B-90283144 |
| Registered address: | C/Averroes nº5, C.P.: 41930, Bormujos, Sevilla. |
| Email contact: | info@hommyhome.com |
What is the purpose of processing your data?
The general purpose for which HOMMYHOME collects your data is to manage your accommodation properly, both concerning clients and property owners.
For your information, we specify the specific purposes for which the data you provide us are used, depending on the different personal data processing activities according to the reason you contact us through the website:
| DATA PROCESSING PURPOSES |
| Processing Activity | Purpose of Data Collection |
| Clients | Accommodation management. Incidents during the stay. Billing for the service provided. Handling suggestions and complaints. |
| Property Owners | Management of accommodations in the owners' properties. |
| Communications | Exchange of communications between employees, clients, property owners, external collaborators, and suppliers. |
| Video Surveillance | Security of people, assets, and facilities of the company or its suppliers. |
What is the legal basis for processing your data?
The legal basis legitimising the data processing activities carried out by HOMMYHOME is as follows:
| Legal Basis |
| Processing Activity | Base legal que permite el tratamiento de datos |
| Clients | Consentimiento. Consent. Contractual relationship. |
| Property Owners | Consent. Contractual relationship. |
| Communications | Contractual relationship. Consent. Legitimate interest. |
| Video Surveillance | Public interest. |
How long do we retain your data?
Your data will be held by HOMMYHOME for the specified periods/criteria. Once their validity has expired, we will proceed to delete and destroy all the data you have provided.
| CONSERVACIÓN DE DATOS |
| Processing Activity | Retention Period/Criteria |
| Clients | Until the end of your stay. They may be retained for statistical purposes or to apply more favourable conditions unless you revoke your consent. |
| Property Owners | 6 years from the end of the contractual relationship between the parties. |
| Communications | Employees: 4 years from the end of the employment relationship. Clients: Until the end of your stay, without prejudice to statistical retention. Property Owners: 6 years from the end of the contractual relationship. External Collaborators/Suppliers: 6 years from the end of the contractual relationship. |
| Video Surveillance | Approximately 15 days from the capture of the images (storage will not exceed 1 month). Controversial snapshots may be subject to claims or requests by law enforcement agencies and will be retained until such claims are concluded. |
*The specified periods/criteria will be followed without prejudice to longer periods/criteria imposed by legal obligations.
What rights can you exercise?
Under current legislation, you have a range of rights that you can exercise by sending your request to the Data Protection Officer (DPO) at Calle Muñoz Olivé nº1, Portal 1 - Floor 3, C.P.: 41001, Seville, or to info@hommyhome.com. These rights are as follows:
| Access: | Obtain confirmation about the processing of your data and the possibility of accessing the data held by the Data Controller. |
| Rectification: | Complete or rectify incomplete or inaccurate data held by the Data Controller. |
| Erasure: | Request the deletion of all data held by the Data Controller about the data subject. |
| Objection: | Request the Data Controller to cease processing activities involving the data held about the data subject. |
| Portability: | Request the transfer of data to the data subject or a new Data Controller indicated by the data subject in a structured, commonly used, and machine-readable format, where technically feasible. |
| Restriction: | Block the processing of your data (except for their retention) for any activity not specifically consented to by the data subject. |
* You can revoke the consent given at any time through the same means available for exercising the other rights mentioned above.
HOMMYHOME will acknowledge receipt of your request and process it within the legally established period of one month, during which you will receive notification of the actions taken in response to your request.
Occasionally, the resolution of your request may be extended by two more months, informing you of this within the period specified above.
The competent body for handling users' complaints is the Spanish Data Protection Agency (AEPD).
Who provides your data?
The data HOMMYHOME obtains through this website are provided directly by the users. In other words, the data subjects themselves enter their data and provide them to us.
HOMMYHOME assumes the accuracy and truthfulness of the entered data, as well as the ownership of the data by the user. HOMMYHOME is not responsible for the entry of personal data into the forms on this website by third parties other than the data subject.
The images captured by the surveillance cameras are obtained directly from the data subjects..
To whom are your data disclosed or communicated?
The data you provide are disclosed to third parties outside HOMMYHOME specified below, with whom the mandatory Data Processing Agreement is maintained and appropriate security measures are implemented:
| DATA DISCLOSURES/COMMUNICATIONS |
| Processing Activity | Third Parties |
| Clients | Property Owners. Tax consultancy. IT provider. Management software. |
| Property Owners | Banking institutions. Tax consultancy. Online rental platforms. Management software. |
| Comunicaciones | Email service provider (Site Ground - Outlook). WhatsApp. |
| Video Surveillance | Surveillance system provider. Law enforcement agencies. |
* The above is without prejudice to communications to law enforcement agencies, courts, and tribunals, public administrations, or public bodies by legal requirement.
What data must you provide for the proper provision of the offered services?
All data requested by HOMMYHOME and provided by you are necessary for the proper achievement of the previously mentioned purposes, in strict compliance with the principles of purpose limitation and data minimisation, as outlined in the General Data Protection Regulation (GDPR) EU 2016/679.
If you do not provide the requested data, HOMMYHOME will be unable to develop the commercial/professional relationship with the required quality standards. Such data include:
| REQUIRED DATA |
| Processing Activity | Data Categories |
| Clients | dentification data (name, ID, address, phone, etc.). Financial data (bank account, card, etc.). |
| Property Owners | Identification data (name, ID, address, phone, etc.). Financial data (bank account, card, etc.). Other data (property identification). |
| Comunicaciones | Identification data (name, address, phone, email, etc.). |
| Video Surveillance | Image (of clients, employees, and property owners moving around the accommodation accesses). |
* The above is without prejudice to those data that, by legal requirement or contractual relationship, must be obtained.
Are automated decisions made or profiles created?
HOMMYHOME does not carry out automated decision-making processes or create profiles as a direct or indirect consequence of the data you provide.
Are international data transfers carried out?
HOMMYHOME does not conduct international transfers of the data you provide. Should the entity need to do so, you will be informed of this in advance, detailing the applicable adequacy decisions, guarantees, binding corporate rules, or specific situations, and providing the means to obtain a copy of such details.